What evidence do auditors commonly ask for on A.3.20 Storage media?

Register of removable media and devices used for PII; Encryption applied to media holding PII, with documented exceptions and their compensating controls; Secure disposal procedure and disposal records for media that held PII.

What is the most common gap auditors find on A.3.20?

Unencrypted USB media in routine use with no record

ISO/IEC 27701:2025 · Annex A Table A.3 information security controls with PII-specific guidance

`A.3.20` Storage media

The organization shall record every use of removable media or portable devices to hold PII and, where practicable, choose media and devices that support encryption. Unencrypted media shall be used only when there is no alternative, and then under procedures and compensating safeguards, tamper-evident packaging for example, since media leaving the premises can easily be lost, damaged or accessed by the wrong people. When media that has held PII reaches end of life, the organization shall document and follow a secure disposal method that leaves the former contents unrecoverable. Media carrying PII shall also be handled under the transfer, logging and authorisation measures set out in A.3.7.

Source: ISO/IEC 27701:2025, A.3.20. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open ISO/IEC 27701:2025 in the compliance library.

artefacts

held by a system

at each review

moderate

to go live

Endpoint management (MDM / EDR)

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

periodic reviewEvidence produced at each review

Secure disposal procedure and disposal records for media that held PII · Data governance / DLP tooling

governing documentDocuments that govern the control

Encryption applied to media holding PII, with documented exceptions and their compensating controls · Policy repository / GRC workspace

First move

Start with the 1 of 3 artefacts that already live in a system (Endpoint management (MDM / EDR)); keep the periodic reviews but log each one as a dated record with a named reviewer.

Common gaps auditors find

Unencrypted USB media in routine use with no record
Disposal by deletion rather than destruction or verified wiping

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

Build my evidence sheet

A.3.19 Clear desk and clear screen · A.3.21 Secure disposal or re-use of equipment